G.R. No. 244048 . February 14, 2022
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

Accused-appellant XXX was charged with two counts of Qualified Trafficking in Persons under Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003). In Criminal Case No. 2013-0202, it was alleged that from September 28, 2012, to April 7, 2013, XXX, by means of deceit, recruited, harbored, and compelled AAA (also known as BBB), a 14-year-old, to work as a waitress and guest relation officer for sexual exploitation.
The prosecution evidence established that on September 28, 2012, AAA, then 14, was recruited by XXX through GGG, the mother of AAA’s friend. XXX promised work as a waitress with a salary. XXX transported AAA and others to a different location, gave them revealing clothes and aliases, and brought them to a KTV bar. AAA’s work involved entertaining customers by drinking with them, allowing them to touch her, entertaining them in a room, and being taken out for sexual intercourse (“bar fine”), with all fees paid to XXX. AAA was not paid her salary, only given advances. Her attempts to leave or escape were prevented; she was caught when she tried. On April 7, 2013, AAA escaped and reported to the police, leading to XXX’s arrest. A medico-legal examination revealed a healed laceration on AAA.
The defense claimed XXX merely recruited AAA to work in her eatery, not a bar, and that AAA and her companions voluntarily went and worked there. XXX denied forcing them into prostitution.
The Regional Trial Court found XXX guilty beyond reasonable doubt of violation of Section 4(a) in relation to Sections 6 and 10 of R.A. 9208 in Criminal Case No. 2013-0202, sentencing her to life imprisonment and ordering her to pay a P2,000,000.00 fine, P500,000.00 moral damages, P100,000.00 exemplary damages, and interest. The Court of Appeals affirmed the conviction with modification, deleting the award of exemplary damages for lack of basis. XXX appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant XXX for Qualified Trafficking in Persons under Section 4(a) of R.A. 9208.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the July 20, 2017 Decision of the Court of Appeals with MODIFICATION. The Court reinstated the award of exemplary damages.
The Court held that all elements of trafficking under Section 3(a) of R.A. 9208, as applied to the acts punished under Section 4(a), were proven beyond reasonable doubt: (1) The act of “recruitment, transportation, transfer, harboring, or receipt of persons” was present through XXX’s acts of recruiting, transporting, and harboring AAA. (2) The means employed included “deceit” as AAA was promised legitimate waitress work but was forced into prostitution. (3) The purpose was exploitation, specifically sexual exploitation through prostitution. The acts were committed against a child (AAA was 14), making it qualified trafficking under Section 6(a) of R.A. 9208, warranting life imprisonment and a fine of P2,000,000.00 to P5,000,000.00.
The Court found AAA’s testimony credible, straightforward, and consistent. Her minor age at the time of the incident was established by her testimony and the stipulation during pre-trial. The defense of denial could not prevail over her positive testimony. The medico-legal finding of a healed laceration corroborated her claim of sexual intercourse.
The Court modified the damages. Moral damages in the amount of P500,000.00 were proper. Exemplary damages in the amount of P100,000.00 were also warranted because the offense was qualified by the minority of the victim. Interest at 6% per annum on all damages awarded from finality until full payment was imposed.